Archives: Air Emissions

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D.C. Circuit Tells EPA Its Policy on Aggregating Sources for Clean Air Act Permitting Violates EPA’s Own Regulations

Following a ruling by the D.C. Circuit, EPA may no longer consider interrelatedness in determining adjacency when making source determination decisions in its Title V or New Source Review permitting decisions under the Clean Air Act.  The decision, which vacates EPA’s policy directive Applicability of the Summit Decision to EPA Title V and NSR Source … Continue Reading

Ohio Imposes New Fugitive Emissions Rules on Horizontal Drillers

The Ohio Environmental Protection Agency (OEPA) has announced new requirements for horizontal drillers aimed at reducing air pollution from so-called “fugitive emissions,” which are generally caused by leaking valves or connectors in drilling equipment. The regulations specifically target methane and other volatile organic compounds (VOCs) used in the drilling process.  The new rules will require … Continue Reading

New Study Measures Methane Emissions During Fracking

The Proceedings of the National Academy of Sciences recently published a study conducted by the University of Texas that measured methane emissions from natural gas production, focusing specifically on emissions at well sites conducting hydraulic fracturing operations. The study included the direct measurement of methane emissions at 190 natural gas sites with 489 wells in … Continue Reading

Climate Change and the Future Regulation of Greenhouse Gas Emissions in the United States: President Obama Introduces New Climate Action Plan

Co-authored by: Erin Rodman On June 25, 2013, President Obama released his Climate Action Plan (the Plan) detailing the current administration’s comprehensive strategy to address climate change. The Plan focuses on “three key pillars” of action: reducing domestic carbon pollution, preparing the United States for the impacts of climate change and leading international efforts to … Continue Reading

USEPA Proposes Updates To Oil And Gas Air Rules For Storage Tanks

Two months ago, the U.S. Environmental Protection Agency (USEPA) requested that a federal judge stay the lawsuits challenging its oil and gas air rule revisions to allow the agency to revisit controversial aspects of the rules.  On Friday, April 12, USEPA published proposed rules revising its prior VOC performance standards for storage tanks used in crude oil and natural gas … Continue Reading

Texas Agencies Announce Rules to Streamline Permitting and Ease Requirements for Oil and Gas Well Operators

In recent weeks, both the Texas Commission on Environmental Quality (TCEQ) and Texas Railroad Commission (TRRC) have proposed rules that would ease requirements for operators. On February 8, 2013, the TCEQ announced that it would propose a rule to streamline the process for authorizing air emissions plans for oil and gas well sites.  The rule … Continue Reading

EPA To Revisit Oil and Gas Air Rules, Requests Stay Of Suit Challenging Regulations

Two weeks ago we reported that Texas withdrew from a multi-party lawsuit challenging USEPA’s new air pollution standards regulating the oil and gas industry (including hydraulic fracturing operations).  The suit is now led by industry petitioners.  On January 16, 2013, six days after Texas’s withdrawal, USEPA filed an unopposed motion asking the Circuit Court for the … Continue Reading

Texas Withdraws From Federal Challenge To USEPA’s Air Standards For Oil And Gas

On January 10, 2013, the State of Texas and two of its agencies (the Railroad Commission of Texas and the Texas Commission on Environmental Quality) filed a joint motion in the Circuit Court for the District of Columbia to voluntarily dismiss their challenge to the U.S. Environmental Protection Agency’s (EPA) new air pollution standards regulating … Continue Reading

Seven States File Notice of Intent To Sue USEPA Over Methane Emission Standards

On December 11, 2012, a group of seven states led by New York Attorney General Eric T. Schneidermann notified the U.S. Environmental Protection Agency (EPA) of their intent to sue the agency.  The states–Connecticut, Delaware, Maryland, Massachusetts, New York, Rhode Island, and Vermont–claim that EPA failed to address methane emissions standards for the oil and gas … Continue Reading

Ohio EPA: Air Quality Near Gas Drilling Site Is Clean

Beginning in April of this year, the Ohio Environmental Protection Agency (Ohio EPA) has been collecting air quality data at a shale gas drilling site located near The Wilds in Muskingum County, Ohio.  Ohio EPA is monitoring for particulate matter (PM), as well as hydrocarbons associated with gas drilling and methane, and will be monitoring … Continue Reading

Shale Boom Is Fueling The Chemical And Energy Production Industries

The rapid expansion in shale gas development portends large future benefits not only for the oil and gas industry, but also for other industries that stand to benefit from affordable and abundant domestic natural gas.  Developments in several such industries have been in the news in the past week.  On October 10, the Pennsylvania DEP … Continue Reading

U.S. EPA Issues Final Air Emissions Rules For Gas Production Wells

Earlier today, U.S. EPA published in the Federal Register its final regulations revising the NSPS and NESHAP for the Oil & Natural Gas Production source category (40 C.F.R. Part 60, Subparts KKK, LLL, and OOOO).  We previously discussed the substance of the draft rules EPA published on April 17, 2012.  EPA’s overview fact sheet, its summaries … Continue Reading

U.S. EPA Issues Air Emission Rules for Oil and Natural Gas Industry

On April 17, 2012, the U.S. Environmental Protection Agency (USEPA) issued final regulations revising the NSPS and NESHAP for the Oil & Natural Gas Production source category (40 C.F.R. Part 60, Subparts KKK and LLL).  As we described earlier this month, USEPA issued the proposed rules on August 23, 2011 and thereafter extended the timeframe for promulgating … Continue Reading

Ohio EPA Issues Final General Air Permit for Shale Production Operations

On February 1, 2012, the Ohio Environmental Protection Agency (“Ohio EPA”) issued a final general air permit to cover natural gas production operations at shale gas well sites in Ohio. The general permit covers emissions from a variety of sources found at most shale gas well sites, such as generators, internal combustion engines, storage tanks … Continue Reading
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